AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

A certified school employee, a wrestling coach, was discharged by the Santa Fe School Board following allegations of sexual misconduct with a female student. The allegations arose after the student disclosed inappropriate touching during a psychological study. The school conducted an investigation, which included interviews with the student, the coach, and other relevant parties, and ultimately recommended the coach's discharge (paras 2-7).

Procedural History

• School Board Hearing: The Santa Fe School Board found just cause to discharge the coach and terminated his employment (para 7).
• Independent Arbitration: An independent arbitrator reviewed the case and concluded that the charges against the coach should be dismissed, but the arbitrator's findings were ambiguous and based on an incorrect standard of review (paras 8-9).

Parties' Submissions

• Appellant (Santa Fe Public Schools): Argued that the arbitrator used the wrong standard of review and should have determined whether the administrator's belief in just cause for discharge was objectively reasonable (paras 15-16, 27).
• Appellee (Coach): Contended that the arbitrator correctly focused on the adequacy of the administrator's investigation and argued that the investigation was incomplete and biased, leading to a lack of evidence supporting the allegations (paras 15-16, 27).

Legal Issues

• Did the arbitrator apply the correct standard of review in evaluating the school board's decision to discharge the coach?
• Should the arbitrator have considered evidence beyond what was available to the administrator at the time of the discharge recommendation?

Disposition

• The Court of Appeals reversed the arbitrator's decision and remanded the case for a new arbitration before a different arbitrator (paras 28-33).

Reasons

Per Fry J. (Bustamante and Castillo JJ. concurring):

• The Court clarified that the arbitrator must conduct a de novo review, which requires evaluating all relevant evidence, including evidence discovered after the notice of intent to discharge, to determine whether the alleged misconduct occurred and constituted just cause for discharge (paras 16-20).
• The arbitrator erred by focusing on the adequacy of the administrator's investigation rather than independently assessing whether the misconduct actually occurred (paras 26-28).
• The statutory language requiring review of "just cause" does not limit the arbitrator to the evidence available at the time of the discharge recommendation but ensures that the charges in the notice are the only basis for discharge (paras 20-22).
• The arbitrator's undue delay in issuing a decision and procedural errors during the appeal process necessitated the appointment of a new arbitrator for the remand (paras 30-32).